Case: County of Santa Clara v. United States Immigration & Customs Enforcement

County of Santa Clara v. United States Immigration & Customs Enforcement et al.

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against ECG 6 LLC, Edward Frost, Markwayne Mullin, United States Department of Homeland Security, United States General Services Administration, United States Immigration & Customs Enforcement, David Venturella ( Filing fee $ 405, receipt number ACANDC-22084819.). Injunction against the US government/official or APA vacatur requested. Filed by State of California, County of Santa Clara. (Attachments: # 1 Exhibit)(Zinn, Matthew) (Filed on 6/10/2026) (Entered: 06/10/2026)

1 Exhibit

View on PACER

NOTICE of Appearance filed by Stacy Jayne Lau on behalf of State of California (Lau, Stacy) (Filed on 6/10/2026) (Entered: 06/10/2026)

Case assigned to Magistrate Judge Susan van Keulen. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 6/24/2026. (mxg, COURT STAFF) (Filed on 6/10/2026) (Entered: 06/10/2026)

NOTICE of Appearance filed by William J White on behalf of County of Santa Clara (White, William) (Filed on 6/10/2026) (Entered: 06/10/2026)

NOTICE of Appearance filed by Caleb Hersh on behalf of County of Santa Clara (Hersh, Caleb) (Filed on 6/10/2026) (Entered: 06/10/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

~Util - Case Assigned by Intake

Proposed Summons. (Zinn, Matthew) (Filed on 6/11/2026) (Entered: 06/11/2026)

NOTICE of Appearance filed by Erin C Ganahl on behalf of State of California (Ganahl, Erin) (Filed on 6/11/2026) (Entered: 06/11/2026)

NOTICE of Appearance filed by Meredith Anne Johnson on behalf of County of Santa Clara (Johnson, Meredith) (Filed on 6/11/2026) (Entered: 06/11/2026)

NOTICE of Appearance filed by Kavita Kandala Narayan on behalf of County of Santa Clara (Narayan, Kavita) (Filed on 6/11/2026) (Entered: 06/11/2026)

NOTICE of Appearance filed by Rajiv Narayan on behalf of County of Santa Clara (Narayan, Rajiv) (Filed on 6/11/2026) (Entered: 06/11/2026)

Initial Case Management Scheduling Order with ADR Deadlines: Case Management Statement due by 9/1/2026. Initial Case Management Conference set for 9/8/2026 09:30 AM in San Jose, - Videoconference Only. (kmg, COURT STAFF) (Filed on 6/11/2026) (Entered: 06/11/2026)

Proposed Summons. (Zinn, Matthew) (Filed on 6/11/2026) (Entered: 06/11/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

Electronic Filing Error

Electronic filing error. Only One Summons will be Issued. Include all Defendants and their Addresses on One Summons. Include an Attachment Page if Necessary. This filing will not be processed by the clerks office.Please re-file in its entirety. Re: 6 Proposed Summons filed by State of California, County of Santa Clara (kmg, COURT STAFF) (Filed on 6/11/2026)

NOTICE of Appearance filed by Jessica Susan Durney on behalf of State of California (Durney, Jessica) (Filed on 6/12/2026) (Entered: 06/12/2026)

NOTICE of Appearance filed by Ashley Elizabeth Werner on behalf of State of California (Werner, Ashley) (Filed on 6/12/2026) (Entered: 06/12/2026)

NOTICE of Appearance filed by Elizabeth Gianna Pianca on behalf of County of Santa Clara (Pianca, Elizabeth) (Filed on 6/12/2026) (Entered: 06/12/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

NOTICE of Appearance filed by Sonia Wills on behalf of County of Santa Clara (Wills, Sonia) (Filed on 6/15/2026) (Entered: 06/15/2026)

NOTICE of Appearance filed by Leily Arzy on behalf of County of Santa Clara (Arzy, Leily) (Filed on 6/15/2026) (Entered: 06/15/2026)

Summons Issued as to ECG 6 LLC, Edward Forst, Markwayne Mullin, United States Department of Homeland Security, United States General Services Administration, United States Immigration & Customs Enforcement, David Venturella, U.S. Attorney and U.S. Attorney General (far, COURT STAFF) (Filed on 6/15/2026) (Entered: 06/15/2026)

CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by County of Santa Clara.. (Zinn, Matthew) (Filed on 6/15/2026) (Entered: 06/15/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

CLERK'S NOTICE OF IMPENDING REASSIGNMENT TO A U.S. DISTRICT COURT JUDGE: The Clerk of this Court will now randomly reassign this case to a District Judge because either (1) a party has not consented to the jurisdiction of a Magistrate Judge, or (2) time is of the essence in deciding a pending judicial action for which the necessary consents to Magistrate Judge jurisdiction have not been secured. You will be informed by separate notice of the district judge to whom this case is reassigned. ALL HEARING DATES PRESENTLY SCHEDULED BEFORE THE CURRENT MAGISTRATE JUDGE ARE VACATED AND SHOULD BE RE-NOTICED FOR HEARING BEFORE THE JUDGE TO WHOM THIS CASE IS REASSIGNED. This is a text only docket entry; there is no document associated with this notice. (rap, COURT STAFF) (Filed on 6/18/2026) (Entered: 06/18/2026)

ORDER REASSIGNING CASE IT IS ORDERED that this case is reassigned using a proportionate, random and blind system pursuant to General Order No. 44 to Judge Eumi K. Lee. Magistrate Judge Susan van Keulen no longer assigned to the case. Counsel are instructed that all future filings shall bear the updated judicial initials immediately after the case number. Counsel are reminded to verify the location of the judge on the court website. All hearing and trial dates presently scheduled are vacated. However, existing briefing schedules for motions remain unchanged. Motions must be renoticed for hearing before the judge to whom the case has been reassigned, but the renoticing of the hearing does not affect the prior briefing schedule. Other deadlines such as those for ADR compliance and discovery cutoff also remain unchanged. Mark B. Busby Clerk, United States District Court (This is a text-only entry generated by the court. There is no document associated with this entry.) (jnk, COURT STAFF) (Filed on 6/18/2026) (Entered: 06/18/2026)

CLERK'S NOTICE RESETTING CASE MANAGEMENT DEADLINES FOLLOWING REASSIGNMENT. Case Management Statement due by 9/23/2026. Initial Case Management Conference set for 10/7/2026 at 01:30 PM before Judge Eumi K. Lee. This proceeding will be held via a Zoom meeting.Court Appearances: Advanced notice is required of counsel or parties who will be present at the hearing. A list of names and emails must be sent to the CRD at eklcrd@cand.uscourts.gov no later than 10/5/2026 at 5:00 PM PT.Civ LR 77-3(d). Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited. (This is a text-only entry generated by the court. There is no document associated with this entry.) (lrt, COURT STAFF) (Filed on 6/18/2026) (Entered: 06/18/2026)

Clerk's Notice of Impending Reassignment - Text Only

Case Referred to Magistrate Judge for Discovery

Case Assigned/Reassigned

Clerk's Notice Setting Zoom Hearing

CASE REFERRED to Magistrate Judge Nathanael M. Cousins for Discovery. (jnk, COURT STAFF) (Filed on 6/18/2026)

NOTICE of Appearance filed by Cristina R. Stella on behalf of County of Santa Clara (Stella, Cristina) (Filed on 6/21/2026) (Entered: 06/21/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed by County of Santa Clara, State of California. Motion Hearing set for 10/7/2026 10:00 AM in San Jose, Courtroom 7, 4th Floor before Judge Eumi K. Lee. Responses due by 7/13/2026. Replies due by 7/20/2026. (Attachments: # 1 Proposed Order Granting Plaintiffs' Motion for Preliminary Injunction)(Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

1 Proposed Order Granting Plaintiffs' Motion for Preliminary Injunction

View on PACER

Declaration of Deputy Director Michael Balliet in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A Notice of Inspection and Response March 3 2005, # 2 Exhibit B Notice of Inspection and Response Feb 5 2007, # 3 Exhibit C Notice of Inspection and Response Feb 21 2007, # 4 Exhibit D Notice of Inspection and Response March 9 2009, # 5 Exhibit E DAO Syngenta Compliant Dec 14 2009, # 6 Exhibit F MF Syn Closure Report Nov 2009, # 7 Exhibit G Site Closure Photos Aug 8 2009, # 8 Exhibit H MF Syn RWQCB Referral Ltr Jan 4 2010)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Principal Planner Samuel Gutierrez in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A GIS Property Profile, # 2 Exhibit B 1993 Use Permit and Conditions of Approval, # 3 Exhibit C GSA Memorandum June 21 2023)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Environmental Health Program Manager Darius Haghighi in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A SJ Spotlight Article and Construction Documents, # 2 Exhibit B Septic Permitting Records, # 3 Exhibit C FEMA Flood Hazards Map)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Robert Hamilton in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A Hamilton CV)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of County Counsel Investigator Ricardo Murillo in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A ROW Photo April 27 2026, # 2 Exhibit B ROW Photo April 27 2026, # 3 Exhibit C ROW Photo April 27 2026, # 4 Exhibit D ROW Photo May 4 2026, # 5 Exhibit E ROW Photo May 11 2026, # 6 Exhibit F SJ Spotlight Article May 13 2026, # 7 Exhibit G ROW Photo May 29 2026, # 8 Exhibit H Mercury News Article June 1 2026, # 9 Exhibit I ROW Photo June 3 2026, # 10 Exhibit J ROW Photo June 15 2026, # 11 Exhibit K ROW Photo June 15 2026, # 12 Exhibit L GSA Solicitation Notice, # 13 Exhibit M GSA Award Notice, # 14 Exhibit N ECG Screenshot of Properties, # 15 Exhibit O ECG Articles of Organization, # 16 Exhibit P ECG Amendment Articles of Incorporation, # 17 Exhibit Q Statement of Information ECG6 Jan 24 2025, # 18 Exhibit R Statement of Information ECG6 Feb 18 2026, # 19 Exhibit S Elmwood Capital Group Statement of Information Mar 15 2023, # 20 Exhibit T Project Salt Box FOIA Letter, # 21 Exhibit U CATEX NEPA MEMO, # 22 Exhibit V Floodplain Memo FOIA)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Hazardous Compliance Materials Division Program Manager Mickey Pierce in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit A 1995 Chemical Inventory, # 2 Exhibit B 1996 Chemical Inventory, # 3 Exhibit C 2007 Chemical Inventory, # 4 Exhibit D Hazardous Waste Manifests, # 5 Exhibit E 2020 Notice of Inspection, # 6 Exhibit F Septic sampling results, # 7 Exhibit G 2009 to 2012 Syngenta Business Disclosure, # 8 Exhibit H Inspection Site Map, # 9 Exhibit I Communication with Property Owner Representative)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Matt Read in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Thuy Van Tsang in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit 1 ECG6 Lease Jan 8 2025)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Request for Judicial Notice re 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Proposed Order Granting Plaintiffs' Request for Judicial Notice)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Leily Arzy in Support of 33 Request for Judicial Notice, filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit 1 DHS NEPA Directive 023-01, # 2 Exhibit 2 DHS NEPA Instruction Manual 023-01, # 3 Exhibit 3 ICE Directive 11087.2, # 4 Exhibit 4 GSA PBS 1999, # 5 Exhibit 5 Space Room Design, # 6 Exhibit 6 General Clause Ex E-3517B, # 7 Exhibit 7 Purchase Order to PRICE MODERN LLC, # 8 Exhibit 8 NOAA Presentation June 15 2026, # 9 Exhibit 9 SCC General Plan Book B Excerpts, # 10 Exhibit 10 NH Press Release Feb 12 2026, # 11 Exhibit 11 Seacoastonline NH Article Feb 27 2026, # 12 Exhibit 12 Liggins Court Records)(Related document(s) 33 ) (Zinn, Matthew) (Filed on 6/24/2026) (Entered: 06/24/2026)

Declaration of Erin Chappell in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/25/2026) (Entered: 06/25/2026)

Declaration of Dr. Tiffany Yap, D.Env. in Support of 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities filed byCounty of Santa Clara, State of California. (Attachments: # 1 Exhibit 1 US Geo Survey Species Query, # 2 Exhibit 2 IBA Species List)(Related document(s) 24 ) (Zinn, Matthew) (Filed on 6/25/2026) (Entered: 06/25/2026)

SUMMONS Returned Executed by State of California, County of Santa Clara. ECG 6 LLC served on 6/30/2026, answer due 7/21/2026; Edward Forst served on 6/23/2026, answer due 7/14/2026; Markwayne Mullin served on 6/23/2026, answer due 7/14/2026; United States Department of Homeland Security served on 6/23/2026, answer due 7/14/2026; United States General Services Administration served on 6/23/2026, answer due 7/14/2026; United States Immigration & Customs Enforcement served on 6/23/2026, answer due 7/14/2026; David Venturella served on 6/23/2026, answer due 7/14/2026. (Attachments: # 1 Certificate/Proof of Service by Certified Mail, # 2 Certificate/Proof of Service by Personal Service)(White, William) (Filed on 7/1/2026) (Entered: 07/01/2026)

CERTIFICATE OF SERVICE by County of Santa Clara, State of California re 33 Request for Judicial Notice, 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities (White, William) (Filed on 7/1/2026) (Entered: 07/01/2026)

NOTICE of Appearance filed by Gregory Alan Nylen on behalf of ECG 6 LLC (Nylen, Gregory) (Filed on 7/8/2026) (Entered: 07/08/2026)

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

STIPULATION WITH PROPOSED ORDER re 1 Complaint,, 24 MOTION for Preliminary Injunction ; Memorandum of Points and Authorities STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE FOR PRELIMINARY INJUNCTION MOTION filed by Edward Forst, Markwayne Mullin, United States Department of Homeland Security, United States General Services Administration, United States Immigration & Customs Enforcement, David Venturella. (Swoopes, Roman) (Filed on 7/13/2026) (Entered: 07/13/2026)

ORDER Granting AS MODIFIED 40 Stipulation Regarding Briefing Schedule for Preliminary Injunction Motion. Signed by Judge Eumi K. Lee.(lrt, COURT STAFF) (Filed on 7/13/2026) (Main Document 41 replaced on 7/13/2026) (lrt, COURT STAFF). (Entered: 07/13/2026)

Notice of Appearance/Substitution/Withdrawal of Attorney

Notice of Appearance/Substitution/Withdrawal of Attorney

Certificate of Interested Entities

Motion for Leave to File

1 Exhibit Brief of Amici Curiae Monterey County and Other Bay Area and Central Coa

View on RECAP

2 Exhibit Proposed Order

View on RECAP

Certificate of Interested Entities

Motion to File Amicus Curiae Brief

1 (Attached Brief)

View on RECAP

2 (Proposed Order)

View on RECAP

Notice of Appearance/Substitution/Withdrawal of Attorney

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

Supplemental Brief

Notice of Appearance/Substitution/Withdrawal of Attorney

Notice of Appearance/Substitution/Withdrawal of Attorney

Notice of Appearance/Substitution/Withdrawal of Attorney

Certificate of Interested Entities

Opposition/Response to Motion

Opposition/Response to Motion

Declaration in Support

Declaration in Support

Notice of Appearance/Substitution/Change/Withdrawal of Attorney

Stipulation and Proposed Order

Order on Stipulation